CA11: 4A IAC claim fails on merits of search issue

Petitioner’s IAC claim against defense counsel for not pursuing a Fourth Amendment claim was properly denied for lack of standing on the merits. Virgil v. Sec’y, Dept. of Corrections, 2019 U.S. App. LEXIS 23777 (11th Cir. Aug. 8, 2019).*

Defendant’s search claim was known before trial and waived. Onyelobi v. State, 2019 Minn. LEXIS 433 (Aug. 7, 2019).*

Defendant’s Carpenter claim in a new trial motion is denied. Carpenter was four months after trial, and the evidence was admissible under the good faith exception. United States v. Brown, 2019 U.S. Dist. LEXIS 131958 (C.D. Cal. Aug. 5, 2019).*

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